Incident Tracker / United States (federal)
DeVita v. Midtown Motors
On 2026-03-25, U.S. District Court for the Middle District of Alabama dismissed the complaint without prejudice and warned that hallucinated citations and shotgun pleading defects did not state a claim. A self-represented party submitted a complaint with fabricated or nonexistent authorities, including Lipham v. General Motors LLC and Zinnerman v. Williams.
- Court
- United States District Court for the Middle District of Alabama
- Date
- 2026-03-25
- Who used the AI
- Litigant in person
- AI tool
- Not identified in the record
- Conduct
- DeVita's amended complaint and objections cited many cases the court could not locate and appeared to include hallucinated case citations.
- Outcome
- Dismissal
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Provisional — written by the court-decisions pipeline, awaiting the editor
- Last checked
- 2026-09-08
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
Similar incidents on the record
- Thomas v. Pangburn, No. 4:23-cv-00046-RSB-CLR (CV423-046) (S.D. Ga.)2023-10-06 · US District Court, Southern District of Georgia (Savannah Division) · DismissalIn the Southern District of Georgia, Magistrate Judge Christopher L. Ray found that pro se plaintiff Jerry Thomas cited ten nonexistent cases and never explained their origin, recommended dismissal of his amended compla…
- Carter v. City of Buffalo, No. 25-CV-740 (W.D.N.Y.)2026-09-08 · US District Court, Western District of New York · WarningIn the US District Court for the Western District of New York, self-represented plaintiff Zakkiyya Carter used case law the court said did not support her propositions, after an earlier screening order. Judge John L. Si…
- Ashmeade v. Amazon.com Services LLC, No. 7:23-cv-04331-KMK-VR (S.D.N.Y.)2026-08-27 · US District Court, Southern District of New York · WarningIn the Southern District of New York, self-represented plaintiff Keith Ashmeade cited two nonexistent Southern District decisions while litigating discovery issues against Amazon. Magistrate Judge Reznik identified the…
- Johnson v. Nationstar Mortgage LLC, No. 1:25-cv-00855-JRR (D. Md.)2026-08-26 · US District Court, District of Maryland · WarningIn the District of Maryland, self-represented plaintiff Darrin Johnson again cited a case the court could not locate, after an earlier Rule 11 warning. Judge Rubin said the authority appeared to be hallucinated from gen…
Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “DeVita v. Midtown Motors”, safelegalai.com/tracker/michael-a-devita-v-midtown-motors-et-al (accessed 2026-10-07). Data: CC BY 4.0.